In particular, in late 2024 it introduced corporate liability for bribery of foreign officials.

Law of 26 December 2024 No. 4111-IX, among other things, expanded the list of officials by including in it:

• Officials of foreign states (holding positions in different authorities or exercising public functions for authorities);
• Foreign arbitrators, individuals authorised to solve non-trial civil, commercial or labour disputes in foreign countries;
• Officials of international organisations (employees or any other individuals authorised by the organisation to act on its behalf);
• Members of international parliamentary assemblies which Ukraine is a member to;
• Judges and officials of international courts.

Under the Law, a legal person can be held criminally liable also for bribery of the listed foreign officials in the event that the actual circumstances providing evidence of the following have been established:

1. Commission by its authorised person, founder (participant), beneficial owner or member of the supervisory board on behalf and/or in the interest of the legal person of a crime provided for by article 209 [legalization (laundering) of proceeds of crime], 369 [offer, promise or provision of undue advantage to an official], 369-1 [trading in influence] or 369-2 [unlawful influence on the outcome of official sport competitions] (hereinafter, a corruption crime);
2. Failure to fulfill the obligations imposed on the person authorised by a legal person deriving from law or constituent documents to adopt corruption prevention measures, which has resulted in the commission of a corruption crime on behalf and/or in the interest of the legal person;
3. Failure to fulfill the obligations imposed on the person authorised by a legal person deriving from law or constituent documents to exercise oversight and/or control of the actions of the persons acting on behalf of the legal person or at the request of its authorised persons, members of its collegial bodies or employees, which resulted in a corruption crime;
4. Commission of a corruption crime on behalf and/or in the interest of a legal person with the consent of its authorised persons, founder (participant) of the supervisory board.

In order to hold a legal person liable, it is unnecessary to define a specific natural person, whose act or omission has elements of a corruption crime.

Organisations can be subject to financial sanctions in the form of a fine, the amount of which depends on the gravity of the crime (minor offences are punishable by a fine ranging between 10,000 and 20,000 non-taxable minimum incomes of citizens (MICs); serious crimes are punishable by a fine between 20,000 and 2,000,000 MICs; particularly serious crimes are punishable by a fine between 75,000 and 7,000,000 MICs) and special confiscation of the profit, assets and other property of the organisation that:

• are proceeds of a crime or/and are direct proceeds of the property that proceeds from a crime;
• were intended to (used with the aim to) finance or provide material support to a crime or reward for its commission;
• were the subject of a crime (except for the property returned to the proprietor (legitimate owner) or, if the proprietor (owner) is not established, transferred to the ownership of the State;
• were used as instrumentalities of a crime (except for the property returned to the proprietor (legitimate owner) who did not know and could not know about its illegal use).

Additionally, non-financial sanctions can be imposed on an organisation for a period between six months and three years, including:

• Restricting its activities, for example, by debarring it from participating in public and defense procurement, leasing public and communal property, using licenses;
• Restricting it in getting the rights and advantages also by prohibiting it from getting benefits and funds from the State, public assistance or international financing.

At the same time, the adopted Law contains ambiguous provisions criticized by experts. In particular, the amendments to the Criminal Procedure Code provide that law enforcement bodies will be able to temporarily restrict the activity of a legal person before any formal charges are issued if there are “sufficient grounds to believe” that the company can hamper the investigation. Specifically, the organisation under investigation can be prohibited, by a court decision, from amending the constituent documents, disposing of certain assets, liquidating the business, as well as subject to restrictions in concluding important deals. What is more, law enforcement, with the same wording – “sufficient grounds to believe” – can request that an investigating judge considers enforcing such measures against the organisation without summoning a representative of the legal person. Some experts stress that the use of such subjective grounds can result in abuse by investigators or prosecutors and covert pressure on businesses: the threat of multi-million fines and the possibility to completely paralyze the activities of the company before a court decision is issued can incentivize businesses to “settle”, both formally via an agreement with the investigation, and informally by offering a bribe to law enforcement.

On 17 July, Law of 16 June 2025 No. 4496-IX entered into force. It provides, among other things, for the change in liability measures for corruption offenses and conditions for their enforcement. It is highlighted that its authors count over 90 persons many of whom are under ongoing anti-corruption investigations by law enforcement or journalists.

The Law, in particular, introduces the following amendments:

• Increased threshold sum that entails administrative liability for submitting knowingly false information in the income declarations of an official – from 150 to 750 subsistence minimums for employable persons (SMs; from UAH 454,000 to 2,270,000) [current threshold ranges from 100 to 500 SMs (from UAH 302,000 to 1,510,000)];
• Increased threshold sum that will entail criminal liability for disclosing false information: under paragraph one of article 266-2 of the Criminal Code – from 750 to 2,500 SMs (from UAH 2,270,000 to 7,750,000) [the current threshold ranges between 500 and 2,000 SMs (from UAH 1,510,000 to 6,060,000)]; under paragraph two of article 266-2 of the Criminal Code – over 2,000 SMs (UAH 7,570,000) [the current threshold is over 2,000 SMs (UAH 6,060,000)];
• Increased maximum fine for declaring false information under paragraph one of article 266-2 of the Criminal Code from UAH 68,000 to 102,000;
• Introduction of the following sanctions for declaring false information under paragraph two of article 266-2 of the Criminal Code: a fine from UAH 102,000 to 136,000, or community works for a period between 150 and 240 hours, or restriction of freedom for up to two years, or imprisonment for up to two years and the deprivation of the right to hold certain positions or undertake certain activities for up to three years;
• Decreased threshold value of the difference between the cost of the assets acquired and the income of the official that gives grounds for liability for illicit enrichment – 3,000 SMs (UAH 9,080,000) [the current threshold is set at 6,500 of non-taxable MICs (UAH 9,840,000)];
• Change of investigative jurisdiction: in particular, the National Anti-Corruption Bureau of Ukraine (NABU) will now investigate only the crimes the amount of the subject of which exceeds at least by 500 times SMs (i.e. is over UAH 15,140,000; the previous threshold was of UAH 6,000,000); the other crimes will be addressed by the State Bureau of Investigation (SBI);
• Prohibition to recruit in Ukraine’s Armed Forces and other military units the individuals accused of a serious and/or a particularly serious corruption crime and the criminal prosecution against whom is at the stage of court proceedings.

At the same time, the Law contains ambiguous provisions limiting the monitoring of officials’ lifestyles to the duration of their office – only the assets, income, expenses, services and other elements of the lifestyle acquired, made or received by the individual during his/her office can be subject to such monitoring. Additionally, certain categories of individuals who are not officials but provide public services can now be subject to the monitoring, in particular, auditors, notaries, private executors, appraisers, as well as experts, arbitration managers, independent intermediaries, members of labour arbitration, arbitrators etc.

The Law has been criticised by the National Agency on Corruption Prevention (NACP) and other experts. It has been stressed, in particular, that:

• The suggested changes concerning the limitation of the monitoring of lifestyles to the duration of office actually allows unscrupulous officials to legalize their corruption assets acquired before the assumption of office, as well as to dispose of them after termination. In particular, officials can declare the assets and property they actually do not have before assuming office in order to justify their illegal income received during their office at a later stage, and can have no concerns at all that the “stolen” public funds they hold will be detected after termination and have the time to legalize them. The NACP will not be able to check the property if the declarant has registered it on third parties or uses it without being its direct owner;
• Increased thresholds for liability for false information in declarations will lead to a situation where it will be more difficult to hold officials liable;
• Decreased threshold for criminal liability for illicit enrichment that at first glance seems to be a positive step, in practice can limit the possibilities for confiscation of property to the revenue of the State. Today for instance, if the value of illegal property is below UAH 9,800,000 (the current threshold) it can still be confiscated within civil confiscation proceedings, i.e. a simplified procedure that is swifter and more efficient than criminal prosecution. If the threshold is lowered, as the Law suggests, many such cases will not fall anymore under civil confiscation, which will hinder the effectiveness of recovery of illegally acquired property to the State;
• Restricted powers of the NACP limited to the investigation of only important crimes actually means that the investigation of “less expensive” offences even with regard to top officials and deputies will be undertaken by the SBI subordinate to the Office of the President, which can hamper the efficiency of investigations and increases the risks of impunity.

In June, the Verkhovna Rada also considered bill no. №13165-2 that, in the opinion of some researches, will transform the system of verification of integrity of judges into a formality once it is adopted.

In order to obtain the EU financial aid of €59 billion under the Ukraine Facility programme, Ukraine should improve the system of verification of integrity declarations of judges by the 2nd quarter of 2025. The bill under consideration has become an alternative version of relevant amendments (other bills – no. 3165 and no. 13165-1) and, in the opinion of experts, the worst of them; nevertheless, it was taken by the Verkhovna Rada as the basis for the future law.

The bill provides that judges must submit a single declaration of integrity and family relationships on an annual basis by 1 May where they will:

1. Declare:

• legality of the source of their property,
• compatibility of the lifestyle of the judge and his/her family members with the property owned and income received,
• absence of grounds for holding the judge disciplinary liable,
• faithful discharge of duties by the judge and respect for the Code of Judicial Ethics,
• absence of actions to acquire the citizenship (nationality) of a foreign State,

2. Submit information on the family name, name and patronymic of the persons having family relationship with them, if these persons hold or held senior public positions in the last five years.

Based on the information that can indicate that the statements or data provided in the declaration are false (either incomplete), the High Qualification Commission of Judges (Commission) undertakes verification of integrity in accordance with the procedure established by the Regulations of the Commission. Only the information for the last reporting period can be subject to verification. The findings of the verification will be inserted in the judicial dossier; in the event that violations are confirmed, the materials will be automatically forwarder to a disciplinary body. The bill also excluded the norm that allowed dismissing judges for intentionally failing to file the declaration or for filing the declaration with false statements or data.

Experts believe that the bill contains a number of structural flaws, in particular:

• The recommendations of the European Commission, which the drafting of the bill is based on, highlight that “independent experts” shall be involved in the verification procedure. In the opinion of researches, it is evident that European officials meant international experts; however, the absence of a clear definition of this category of individuals allowed the Ukrainian legislators to interpret it in their own way: in particular, the first version of the bill provided that representatives of a certain Public Integrity Council were to be engaged in verifications; the last version completely disregarded the requirement to involve independent experts;
• A regulated verification procedure which the Commission is invited to be guided by is not in place yet, which actually makes this instrument invalid;
• Taking account of the requirement providing that the verification is possible only with regard to the information concerning the last reporting period, and considering the number of judges in the country and the workload of the Commission, it can be assumed that a proper verification will be almost impossible.

Finally, another ambiguous initiative under consideration by the Verkhovna Rada is bill no. 13423 drafted by 126 people’s deputies that actually suggests exempting the officials of enterprises executing state defense orders from liability for corruption if their actions, even if a priori criminal, have a “socially useful purpose”. The list of such enterprises will be closed and confidential; it will be compiled by the Ministry of Defense and not released publicly. The NABU and the Specialized Anti-Corruption Prosecutor’s Office will be unable to investigate the crimes in the defense sector: initiation of criminal prosecution, searches or arrests with regard to the enterprises included in the list will rest exclusively with the Prosecutor-General.

Moreover, the bill suggests not only establishing such a regime for the martial law period, but also maintaining it for three years after it is over, as well as permitting a retroactive “amnesty”, i.e. if a crime is committed by a company before it is included in the relevant list, but under the martial law.

Anti-corruption researches stress that if the bill is adopted, it will actually legalize corruption in the defense sector, especially, for the list of suppliers of the Ministry of Defense agreed in advance: this means that a company pays for “entering” the list of suppliers, “buys” immunity and can further overprice procurement running no risk.

Conversely, some experts believe that the bill was suggested intentionally as knowingly impassable and serves as a “lightening rod” for ensuring the adoption of a number of other bills aimed at establishing a special legal framework for the enterprises manufacturing weapons and military hardware.